The tariff classification of a pad with velcro adhesive from China

 N320673 August 10, 2021 CLA-2-87:OT:RR:NC:N2:206 CATEGORY: Classification TARIFF NO.: 8708.99.8180; 9903.88.03 Patricia Lounis Red Crown Products 2345 W. Foothill Blvd. Upland, CA 91786 RE: The tariff classification of a pad with velcro adhesive from China Dear Ms. Lounis: In your letter, June 30, 2021, you requested a tariff classification ruling. The sample submitted with your letter will be returned to you per your request. The item under consideration is a Neoprene and Nylon Pad with Velcro Adhesive, which is designed for passenger vehicles. It is applied to the existing automotive floor mat. The purpose of the pad is to protect the heel of the shoe from dirt and dye transfer from the existing carpet or rubber floor mat. The wear and friction that occurs when driving causes staining of the shoe heel. The mat serves a secondary purpose, which is protecting the existing floor mat from wear in the place where the heel rests. It appears that CBP reviewed a similar article in HQ 952233, dated February 10, 1993, where the product was determined to be classified in subheading 8708.99, Harmonized Tariff Schedule of the United States (HTSUS), which provides for automotive parts and accessories. The applicable subheading for the Neoprene and Nylon Pad with Velcro Adhesive will be 8708.99.8180, HTSUS, which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other: Other.” The general rate of duty will be 2.5% ad valorem. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 8708.99.8180, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheadings 8708.99.8180, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china respectively. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at https://hts.usitc.gov/current. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Liana Alvarez at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division